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FC-C.2.8

Determining the risks of product, service, transaction or the delivery channel offered to customers may include a consideration of their attributes, as well as any associated risk mitigation measures. Products and services that may indicate a higher risk include:

(a) Wealth management/private banking;
(b) Anonymous transactions (which may include cash);
(c) Non-face-to-face business relationships or transactions;
(d) Payment received from unknown or un-associated third parties;
(e) Products or services that may inherently favour anonymity or obscure information about underlying customer transactions;
(f) The geographical reach of the product or service offered, such as those emanating from higher risk jurisdictions;
(g) Products with unusual complexity or structure and with no obvious economic purpose;
(h) Products or services that permit the unrestricted or anonymous transfer of value (by payment or change of asset ownership) to an unrelated third party, particularly those residing in a higher risk jurisdiction; and
(i) Use of new technologies or payment methods not used in the normal course of business by the investment firm licensee.
Added: January 2022